{"operation":"document","citation":"CPF 120150002W","title":"RICHMOND, CITY OF — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-02-12","effective_on":null,"summary":"CLOSED warning letter citing 192.285(c)(1), 192.605(b)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120150002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120150002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120150002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120150002W","body":"Warning Letter involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulations as 192.285(c)(1),  192.605(b)(3). The case was opened on 2015-02-12 and is reported as closed as of 2015-02-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120150002W_Warning Letter_02122015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150002W/120150002W_Warning%20Letter_02122015.pdf\n\n120150002W_Warning Letter_02122015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150002W/120150002W_Warning%20Letter_02122015_text.pdf\n\n120150002W_Warning Letter_02122015_text.pdf\n\nU.S. Department Of Transportation Pipeline and 609.989.2171\nHazardous Materials\nSafety Administration\n820 Bear Tavern Road, Suite 103\nWest Trenton, NJ 08628\nWARNING LETTER\nOVERNIGHT EXPRESS MAIL\nFebruary 12, 2015\nMr. Robert Steidel\nDirector, City of Richmond\nDepartment of Public Utilities\n730 East Broad Street\nRichmond, VA 23219\nCPF 1-2015-0002W\nDear Mr. Steidal:\nBetween February 24 and August 7, 2014, an inspector from the Virginia State Corporation Commission\n(VA SCC) acting as Agent for the Pipeline and Hazardous Materials Safety Administration (PHMSA),\nOffice of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code inspected the City of\nRichmond’s (City) pipeline facilities in Richmond, Virginia.\nAs a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation(s)\nare:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of this section must\ninclude procedures for the following, if applicable, to provide safety during maintenance and\noperations.\n(3) Making construction records, maps, and operating history available to appropriate operating\npersonnel.\nThe City failed to make accurate construction records, maps, and operating history available to\nappropriate operating personnel.\nThe City’s GIS mapping system had an incorrect valve (retired valve on an old system that was indicated\nas an active valve on a live system) that the City attempted to utilize to stop a gas leak.\nEvidence is based on VA SCC Notice of Investigation (NOI) to the City, and City responses to the VA\nSCC NOI. We understand that the City has corrected the map in question.\n\n\n\n1-2015-0002W\n2. §192.285 Plastic pipe: Qualifying persons to make joints.\nc) A person must be requalified under an applicable procedure, if during any 12-month period that\nperson:\n(1) Does not make any joints under that procedure; or\nThe City failed to re-qualify an individual to perform mechanical joints during any 12-month period in\nwhich that individual does not make any joints under that procedure.\nDuring this inspection on August 7, 2014, VA SCC staff witnessed a Willbros T & D Services crew\ninstalling mechanical joints on a 4 inch plastic main line. The crew foreman performing the joining did\nnot have a current plastic joining task certification card. The foreman’s qualification had expired on July\n17, 2014, 20 days prior to the date of that the joining work was being done. After this discovery, joints\npreviously completed by the foreman were removed and re- installed by an individual on the crew that\nhad current qualifications.\nEvidence is based on VA SCC Notice of Investigation (NOI) to the City, and City responses to the VA\nSCC NOI.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per\nviolation per day the violation persists up to a maximum of $2,000,000 for a related series of violations.\nFor violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per\nviolation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time. We advise\nyou to correct the item(s) identified in this letter. Failure to do so will result in the City being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, please address your correspondence to: Byron\nCoy, PE, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, W. Trenton, NJ 08628\nand please refer to CPF 1-2015-0002W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete\noriginal document you must provide a second copy of the document with the portions you believe qualify\nfor confidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response letter\npertains solely to one CPF case number.\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCc: Mr. James Hotinger, VA SCC\n120150002W_WL_02122015 Page 2 of 2","truncated":false,"body_characters":5398}